This Privacy Notice is intended to provide information about our organisation and our practices with respect to the personal data of individuals in the EEA to the extent (1) that the services are not covered by our national EU privacy policies and (2) we provide these services to you through our U.K.-based or Germany-based affiliates Turtle Beach Europe Limited and Turtle Beach Germany GmbH.
In respect of personal data collected using our website, Voyetra Turtle Beach, Inc. will be a ‘data controller’ in respect of your personal data. A data controller is responsible for deciding the ways in which and purposes for which personal data about you is processed. We may process your personal data ourselves or through others acting as data processors on our behalf.
Throughout this notice, ‘we’ and ‘us’ means Voyetra Turtle Beach, Inc.
‘Personal data’ means any information relating to you, such as your name and contact details, transactional-related data associated with you but does not include data where you can no longer be identified from it such as anonymised, aggregated data.
If you have any questions about this Privacy Notice, you can contact us using the details set out in the ‘Contact Us’ section below.
The EU General Data Protection Regulation (“GDPR”) specifies certain ‘legal bases’ for which we are allowed to use your personal data where that processing is subject to the GDPR. The personal data that we may collect about you and the purposes for which it will be used, as well as the legal basis for such processing are set out in this section.
This website is not targeted at children under the age of 16. If you are under the age of 16, you should not visit this site and, in particular, should not submit any personal data to us.
If you place an order through our website
When you place an order with us on our website we will request certain information from you. This information is likely to include your name, e-mail address, payment card details, billing address, shipping address and telephone number. This information will be used to process your order, arrange delivery of your order and correspond with you in relation to your order. Our legal basis for using your personal data in this way is to perform the contract we enter into with you in respect of your order.
If you place an order with us on our website, your personal data and transactional-related data will be shared with Oracle Bronto. If you opt-out of receiving email communications from us, all such data will be deleted from Oracle Bronto’s systems. Our legal basis for this use and sharing of your personal data is our legitimate interest in engaging in direct marketing.
This personal data is required in order to place an order with us. If you do not provide this information we will not be able to accept your order or fulfil your order.
If you buy a Turtle Beach product, we may also use your contact details to ask you if you would like to review the product that you purchased. You do not need to submit a review, but if you do we may process the personal data that you provide in your review or in connection with your review to publish your review on our website. We will provide you with further information about how we may use your review and associated data when we contact you to ask you to provide a review. Our legal basis for this processing is our legitimate interest in soliciting feedback for our products and promoting our products using customer reviews.
If you sign up to receive e-mail marketing from us
Our e-mail communications are not targeted at children. By opting in to receive e-mail marketing from us, you confirm that you are aged 16 or over.
When you sign up to receive e-mails from us (for example, by ticking a box or clicking a link) we will collect your e-mail address and share it with Oracle Bronto. We will use your e-mail address to send you e-mails with our latest new releases, deals, events, promotions, gaming articles and other promotional material and information about Turtle Beach products. Our legal basis for processing your e-mail address for this purpose is your consent. If you do not provide your e-mail address, we will not be able to send you the e-mails that you request.
If you have signed up to receive communications using one of our websites, we will automatically record which Turtle Beach website you used to join our mailing list. We will use this information to ensure that our communications to you are in the same language as the website that you used. Our legal basis for processing this information is our legitimate interest in ensuring that the communications we send you are in an appropriate language.
We also collect information about whether you open e-mails sent by us to evaluate the effectiveness of our communication, as well as the effectiveness of time and days of our communications. Our legal basis for this processing is our legitimate interest in evaluating the effectiveness of our communications and our marketing strategy.
If you win a prize
From time to time we may engage third parties to conduct social media giveaways and prize promotions or similar activities. If you engage in such activities, the operator of the giveaway or promotion will generally be a data controller in respect of your personal data. If you win a prize and we are responsible for fulfilling your prize, the operator may pass certain personal data that you provided to them (such as your name, address and contact details) on to us so that we can give you your prize. We will only use such personal data to give you your prize, but might not be able to do so if we do not receive the relevant information. Our legal basis for this use of your personal data is our legitimate interest in providing prizes to winners in these kinds of promotions.
As part of a social media giveaway or prize promotion, you may be asked to sign up to receive e-mails from us. Information about signing up to our mailing list is provided above.
If you register your product
If you buy a Turtle Beach product, you can register the product with us.
Product registration is carried out by submitting certain information on our applicable online form. This information is likely to include your name, e-mail address, postal address, details about your product (such as the model, serial number, product platform) and information about your purchase (such as where you purchased the product and the date of purchase).
Product registration is optional. If you choose to register your product, we will use the information that you provided to assist you with technical support or dealing with problems with your product (such as administering warranty claims), if you request. Our legal basis for processing this information for these purposes is our legitimate interest in assisting you efficiently with issues relating to Turtle Beach products where you have chosen to register your product with us. If you do not provide this personal data we may not be able to assist you in these ways or it may be more difficult for us to do so.
If you contact us for technical support
If you contact us for technical support, we may collect certain information from you such as your name, e-mail address, postal address, details about your product (such as the model, serial number, product platform), information about your purchase (such as where you purchased the product and the date of purchase) and other information you provide us in connection with your technical support request. We may also generate certain information such as records of the technical issues with your product and our correspondence with respect to your enquiry.
We use this personal data in order to assist you with technical support, to deal with problems with your product (such as administering warranty claims) and to respond to your enquiry. The legal basis for this processing is that it is in our legitimate interest to assist you efficiently with issues relating to Turtle Beach products when you request. If you do not provide this personal data we may not be able to assist you in these ways.
If you contact us in relation to other matters
If you contact us through our website or otherwise, you may provide personal data to us in the course of your correspondence with us. This may include your name, address, e-mail address, other contact details and your opinions. We may also generate personal data about you in connection with the correspondence, such as correspondence records and opinions.
We may process this personal data to correspond with you, respond to your enquiry or address matters raised by your correspondence. We may not be able to do so if you do not provide this personal data. The legal basis for this processing is our legitimate interests in responding to or addressing your enquiry or otherwise communicating with you in the course of our business.
Please note that if you correspond with Turtle Beach Europe Limited, Turtle Beach Europe Limited will usually be a data controller in connection with that correspondence and any related personal data. Turtle Beach Europe Limited may also use such personal data as described here. Turtle Beach Europe Limited’s contact details are also included in the ‘Contact Us’ section below.
Cookies
Our website uses cookies. These cookies collect information about how you use our website, your previous interactions with our website and technical data (such as your IP address, browser type and version, time zone setting and location). Further information about our use of cookies is set out in the Cookies Policy below. Where cookies collect personal data, the legal basis for our use of cookies and the information collected using cookies is our legitimate interests in:
Other purposes
In addition to the uses above, we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may also process personal data for purposes other than those for which the personal data was originally collected where permitted by applicable data protection laws. Where this is the case, we will provide you with information about that further processing.
Special categories of personal data
There are more limited bases for processing ‘special category’ personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.
We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally (for example, where you volunteer special category data to us, such as if you send us an e-mail containing special category data).
We may share your personal data with a third party where this is required by law or where we have another legitimate interest in doing so.
We may also need to share your personal data with:
Examples of who may process your personal data in different scenarios are set out below.
If you place an order through our website
Our website uses the Shopify online e-commerce platform. When you place an order, in addition to providing such personal data to us, we will share certain data such that Shopify will process your payment details on our behalf.
If you are located in the European Economic Area (‘EEA’), your shipping details may be transferred to our affiliate Turtle Beach Europe Limited to arrange delivery of your order, together with its service providers (such as freight and logistics providers).
If you sign up to receive e-mail marketing from us
When you sign up for our e-mail communications, your personal data and transactional data is collected by Oracle Bronto and then held on a platform maintained by us. Oracle Bronto acts as a data processor on our behalf and process your personal data on our instructions.
We may also share your personal data with third parties in the context of the possible sale or restructuring of our business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We are based in the USA. Your personal data will be held by us or our service providers in the USA and may also be held in other non-EEA jurisdictions. Sometimes we may also transfer your personal data to other jurisdictions outside the EEA. For example, we may use cloud service providers who store personal data on servers in jurisdictions outside the EEA.
The European Commission has not determined that the laws of the USA generally provide an adequate level of protection in respect of personal data. Other non-EEA jurisdictions may similarly not provide the same level of protection in respect of personal data as in the EEA. Where required by the GDPR, we will (or will require a processor to) put in place appropriate safeguards including, but not limited to, the standard contractual clauses approved by the European Commission.
If you sign up to receive e-mail marketing from us, the personal data and transactional data used for such purposes is transferred to Oracle Bronto (who process the relevant data on our behalf) and held in the USA.
If you require further information about this you can request it using the details set out in the ‘Contact Us’ section below.
As indicated above, we rely on your consent as our legal basis to send you e-mail marketing. You have the right to withdraw your consent to this processing at any time.
To withdraw your consent where you have previously consented to direct marketing, you can unsubscribe from direct marketing communications from us by:
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose to which you originally consented unless we now have an alternative legal basis for doing so.
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this we will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For example, we may retain the personal data we use for sending direct marketing e-mail to you for so long as you subscribe to our e-mail mailing list. You can unsubscribe from direct marketing communications from us at any time as explained in section 5 above. We may also remove such personal data in circumstances where you have not unsubscribed, such as where our e-mails to you are failing to deliver to your e-mail address or if you consistently do not open the e-mails that we send.
Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations. Alternatively, the information may be anonymised so that it can no longer be associated with you, in which case it is no longer personal data.
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.
Where the processing of your personal data is within the scope of the GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
If you want to exercise one of these rights please use the contact details set out in the ‘Contact Us’ section below.
You also have the right to make a complaint at any time to a supervisory authority for data protection issues.
Fees
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Our practices with respect to personal data may vary from time to time and we may update this Privacy Notice at any time. In addition, we may provide additional privacy notices that set out information about our privacy practices in other scenarios.
If we intend to process your personal data for a purpose other than the purposes referred to above, we will provide you with additional information about that purpose.
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us using the following contact details: data protection officer, c/o Turtle Beach Germany GmbH, Gasstrasse 4, D 22761 Hamburg, Germany, email: privacy@turtlebeach.com .
